
Tracking Form 5471 Section 959 PTEPs on Schedule J for the Modern Day CFC
By Anthony Diosdi Before enactment of the 2017 Tax Cuts and Jobs Act (“TCJA”), the Internal Revenue Service (“IRS”) Form 5471 was a reasonable exercise. Prior to the enactment of the TCJA, the IRS Form 5471 was approximately two pages long. This all changed with the enactment of the TCJA. The days of preparing two page long Form 5471s are long gone. The IRS Form 5471 along with its accompanying Schedule J has become one of the most difficult tax returns to complete. This is the result of the complexity and incompleteness of the TCJA’s international tax provisions, along with congressional failure to remedy the gaps that TCJA created in the Internal Revenue Code. Thus, the Department of Treasury (“Treasury”) and the IRS are left to bridge the gaps in…